Williams v. Second Judicial District Court of the State of Nevada

Summary

The Nevada Supreme Court holds that the district judge's conduct did not establish disqualifying actual judicial bias under the heightened standard applicable to bias arising from judicial proceedings. However, exercising its supervisory authority, the court concludes that reassignment is warranted because the judge prematurely and repeatedly found the defendant guilty, undermining the appearance of fairness and the presumption of innocence. The petition is therefore granted in part and denied in part, and the case must be reassigned to a different district judge.

Holdings

1. The district court judge was not required to be disqualified for actual judicial bias because the record did not demonstrate deep-seated favoritism or antagonism so extreme that fair judgment was impossible.
2. Even absent statutorily disqualifying judicial bias, the Nevada Supreme Court may invoke its constitutional supervisory authority to order reassignment in exceedingly rare cases when reassignment is necessary to preserve public confidence and trust in the fairness of the proceeding.
3. Reassignment was warranted because the district court's premature, unsupported, and repeatedly stated findings of guilt compromised the appearance of justice and threatened the presumption of innocence.

Questions Presented

1. Whether the district court judge was required to be disqualified for actual judicial bias based on findings and comments in an order denying severance.
2. Whether the Nevada Supreme Court could order reassignment under its supervisory authority even though the evidence did not establish disqualifying judicial bias.
3. Whether reassignment was warranted under the Robin factors because the district court's premature and repeated findings compromised the appearance of justice and the presumption of innocence.

Disposition

writ_granted